The SBA PPP has continued to evolve- 11 interim final rules and continuing iterations of frequently asked questions. The SBA rules concerning forgiveness may be perhaps the area of most significant concerns for bankers and borrowers alike. Yet other traps for the unwary exist in the Form 1502, provisions governing PPPLF, agents, sales of PPP loans, transmittal forms for loan pay-downs and other rules  as well as from regulatory expectations and  “Doe” litigation seemingly against all banks.

 

This presentation will cover the current state of the PPP rules, especially those governing forgiveness.